https://www.taxtmi.com/caselaws?id=762108 A reassessment notice issued beyond four years was invalid because the statutory conditions for reopening were not strictly met. The record showed the reopening proceeded on an incorrect assumption that the assessee was the sole owner of the property, whereas the sale deed reflected co-ownership; the failure to base reopening on accurate material facts undermined the jurisdictional basis for section 148 action. The notice was also treated as issued only upon later service, which fell beyond the limitation period. On these facts, the notice was time-barred and without legal force, and the reassessment proceedings could not be sustained. en-us Mon, 04 Nov 2024 00:00:00 +0530 Mon, 25 Nov 2024 08:45:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762108 A reassessment notice issued beyond four years was invalid because the statutory conditions for reopening were not strictly met. The record showed the reopening proceeded on an incorrect assumption that the assessee was the sole owner of the property, whereas the sale deed reflected co-ownership; the failure to base reopening on accurate material facts undermined the jurisdictional basis for section 148 action. The notice was also treated as issued only upon later service, which fell beyond the limitation period. On these facts, the notice was time-barred and without legal force, and the reassessment proceedings could not be sustained. Case-Laws Income Tax Mon, 04 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762108